Personal Injury Protection (PIP) is mandatory insurance coverage for Florida motor vehicle owners. It covers a limited amount of medical expenses and lost wages, typically $10,000 total.
The PIP statute, s. 627.736, is particular as to which types of medical providers may seek reimbursement. In Geico General Insurance Co. v. Beacon Healthcare Center, Inc. (Fla. 3rd DCA; opinion filed February 26, 2020), the court confirmed that “a person who is licensed as a massage therapist, but not licensed as a physical therapist,” may not be reimbursed by PIP.
A number of GEICO insureds sought treatment at Beacon Healthcare Center, Inc. During their initial consultations, the treating physician (and Beacon’s medical director) prescribed therapy modalities that were provided by massage therapists who held massage therapy licenses, but did not hold licenses in physical therapy. The massage therapists were not directly supervised on site by either a licensed physical therapist or by a medical physician when they performed the treatments.
The PIP statute excludes massage from the types of health care services that may be reimbursed and prohibits massage therapists from being reimbursed. See § 627.736(1)(a)(5), Fla. Stat. (2019) (“Medical benefits do not include massage as defined in s. 480.033 …, regardless of the person, entity, or licensee providing massage … and a licensed massage therapist … may not be reimbursed for medical benefits under this section.”). The court explained:
“While there is some overlap between the two licensed practices, they are different practices requiring different licensures.”
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